Public Knowledge and Open Technology Institute at New America (“PK and
OTI”) submits these Reply Comments regarding the Commission’s Public Notice
seeking comments regarding petitions by Helen Wong-Armijo, FCR, Inc., Skybridge
Spectrum Foundation, and Telesaurus Holdings GB LLC, (collectively,
“Licensees”), for service waivers and construction extensions relating to their
Multilateration Location and Monitoring Service (“M-LMS”) licenses. As in the case of PCS Partners’ requests issued earlier this year, PK
and OTI oppose any grant of extension or waiver for these licenses. The
Licensees in this proceeding have similarly failed to make use of the
extensions already granted them. Additional extensions would run contrary to
past Commission holdings, and would not serve the public interest. Under these
circumstances, the Commission should deny these Petitions.